Safety, maintenance, assurance and approvals amongst main points
With Australia taking tentative steps towards an autonomous vehicle future, a number of trucking and related organisations have responded with submissions.
Preparing the nation for the complexities of autonomous transport of all kinds is part of the NTC’s 2016-2020 corporate plan and the advice follows the release of an issues paper and a discussions paper in February and May.
The Australian Trucking Association (ATA) believes that although heavy vehicles are steadily becoming more automated, “an autonomous or ‘driverless’ truck remains a futuristic concept and is not a current priority for the industry”.
That said, it has already recommended national regulatory consistency on the subject where possible and notes the recent Tesla crash in the US, involving a truck and trailer, as a pointer to risks for trucks in early interactions between autonomous passenger vehicles and standard vehicles.
The ATA also sees proper maintenance and software regimes as crucial.
It also supports no-blame investigations into autonomous vehicle accidents involving technology, safety systems and human factors to allow safety improvements to be made and be able to access data from the autonomous vehicle involved.
Heavy Vehicle Industry Australia (HVIA) has raised at least five key points for the National Transport Commission (NTC) to consider.
Aiming to ensure that future regulatory frameworks meet the needs of the industry, HVIA says its main concern is that the discussion paper’s focus is on individual autonomous vehicles.
“HVIA’s main concern at the moment is that most of the conversation around autonomous vehicles seems to be focusing on individual vehicles, and that not enough attention has been given to the implications for combination vehicles or the implications for the fleet as a whole,” national manager, government relations and policy Greg Forbes says.
“Given that HVIA represents a range of organisations from manufacturers and modifiers of vehicle through to component supplier we are very interested in the full spectrum of impacts on the industry.
Some of the other key comments made in the HVIA submission include:
- in the longer term that some form of safety assurance framework will be required but it is not clear what the scope or structure of the framework should be
- the safe operation of automated vehicles and combinations also needs to consider maintenance of ongoing performance of both individual vehicles and the system
- in most cases modified autonomous vehicles should be required to meet the same standard as unmodified vehicles or be required to seek an exemption if they are not able to comply
- the original manufacturers of the vehicle may need to have a role in providing assurance that autonomous systems in modified vehicles still operate correctly
- the approvals process for autonomous vehicle modifications must be clear and unambiguous.
“HVIA is keen to maintain an ongoing involvement in the development of this important policy issue. It is clear that further work is required before a preferred regulatory framework for autonomous vehicle can be determined,” Forbes says.
“However, it is not clear how consultation on this issue is to be managed going forward.
“NTC may wish to give consideration to what type of forum would be most appropriate for these discussions.”
Regarding on-road trials, the Truck Industry Council (TIC) advocates they be supported with national guidelines to ensure a nationally consistent approach and nationally consistent regulations for such trials.
On the question of how the concepts of ‘control’ and ‘proper control’ of such vehicles should be handled, the TIC wants a short-term holding option to allow trials while the legal definitions are worked out.
The TIC believes that control and proper control must be defined for at least four circumstances:
- human driver in control (that is currently covered by existing regulations)
- autonomous vehicle in control (will likely be specific company or entity, possibly the vehicle OEM, however there needs to be some degree of flexibility in the definition to account for various responsible parties)
- transition from human driver to autonomous vehicle control
- transition from autonomous vehicle control to human driver
“It is the last two definitions that TIC considers critical and the hardest to develop. At this point in time TIC does not offer a specific proposal,” it says.
But it “firmly believes that the above definitions must be in-line with similar definitions developed in the region/s whose autonomous vehicle control regulations Australia will adopt (most likely Europe and the relevant EU Regulations).
“Slight changes may be necessary to satisfy Australian specific legal requirements, however wholesale definition differences will delay or potentially prevent the adoption of autonomous vehicle control technologies in Australia.”
TIC sees a need for heavy vehicle fatigue legislation to be reviewed and reformed as part of the ongoing take-up of autonomous driving functions in heavy vehicles.
“If for example a driver is able to relax and rest whilst physically in a moving truck, where the driving functions/control of the truck is being performed by an autonomous driving system, then this rest/break time should be acknowledged and factored into the drivers fatigue management regime and their allowable driving hours,” it says.